DOJ-OGR-00006585.pdf

--- Page 1 --- The extracted text is as follows: **Header:** * Case 1:20-cr-00330-PAE * Document 442-1 * Filed 11/12/21 * Page 2 of 3 * U.S. Department of Justice * United States Attorney Southern District of New York **Letterhead:** * The Silvio J. Mollo Building * One Saint Andrew's Plaza * New York, New York 10007 **Date:** * October 11, 2021 **Email Address:** * BY ELECTRONIC MAIL **Sender and Recipients:** * Christian Everdell, Esq. * Cohen & Gresser LLP * 800 Third Avenue * New York, NY 10022 * Laura Menninger, Esq. * Jeffrey Pagliuca, Esq. * Haddon, Morgan and Foreman, P.C. * 150 East Tenth Avenue * Denver, CO 80203 * Bobbi Sternheim, Esq. * Law Offices of Bobbi C. Sternheim * 33 West 19th Street-4th Fl. * New York, NY 10007 **Re:** * United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) **Dear Counsel:** * We write to notify you that the Government may seek to introduce certain evidence at trial. In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition to the defendant's conduct with Jeffrey Epstein, the defendant took steps to please other influential men by providing them with access to women she selected for them. * We are producing these proposed exhibits today, marked with the following exhibit numbers: GX 401 through 404, GX 409 through 410, and GX 413. * In addition, please be advised that the Government may call as a witness at trial. Today, we are producing Jencks Act materials relating to Jeffrey Epstein from The Government anticipates that will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls. **Footer:** * DOJ-OGR-00006585